Sample · Texas · frozen Sep 26, 2026

This is the Compliance Brief a Solo-State or All Access member with Texas selected receives — rendered by the same code from the same published records, with nothing written for the sample. It is a snapshot: it holds only what we had published by Sep 26, 2026 and is not kept current. A member’s copy is generated live from their own states.

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MedSpaRadar

Compliance Brief

Scope: TX — All topics · Sample snapshot as of 2026-09-26 · Monitoring, not legal advice

1 · Regulatory changes affecting your practice

81 material changes in scope · 350 background records listed in section 4

Action required (31)

Each of these carries a specific instruction. Work through this list first.

TX · LegiScan · 2025-06-20
TX HB3749: Relating to the regulation of the provision of elective intravenous therapy.
Texas HB 3749 regulates elective IV therapy; effective Sept 1, 2025.
What to do: Beginning September 1, 2025, review your practice's protocols for elective intravenous therapy administration as required by HB3749, ensuring compliance with new delegation rules for physician supervision.
Source: https://capitol.texas.gov/BillLookup/History.aspx?LegSess=89R&Bill=HB3749
TX · LegiScan · 2025-05-15
TX SB2696: Relating to the regulation of the performance of cosmetic injections; requiring an occupational certificate; authorizing fees.
Certification required for cosmetic injectors in Texas by 2026.
What to do: Prepare to apply for the new cosmetic injector certificate starting September 1, 2026, as SB2696 mandates licensing for all cosmetic injection providers in Texas.
Source: https://capitol.texas.gov/BillLookup/History.aspx?LegSess=89R&Bill=SB2696
TX · LegiScan · 2025-05-08
TX SB1117: Relating to the administration of botulinum toxin by dentists.
TX SB1117 allows dentists to inject botulinum toxin by 2025.
What to do: Be prepared for new rules regarding the administration of botulinum toxin, as SB1117 requires the State Board of Dental Examiners to adopt these by December 1, 2025.
Source: https://capitol.texas.gov/BillLookup/History.aspx?LegSess=89R&Bill=SB1117
Federal · Primary Source Monitoring · 2026-09-21
Primary Source Monitoring: Former Connecticut Resident Guilty of Operating Websites to Illegally Sell Misbranded and Unapproved Drugs
Caution urged due to recent conviction for selling misbranded drugs.
What to do: Check whether you ever bought peptides from pinnedaminos.com or projectaminos.com; a federal jury convicted their operator on September 18, 2026 of selling misbranded, unapproved drugs labelled "for research use only".
Source: https://www.justice.gov/usao-ct/pr/former-connecticut-resident-guilty-operating-websites-illegally-sell-misbranded-and
Federal · Primary Source Monitoring · 2026-09-17
Primary Source Monitoring: Korea Filler Experts - 718706 - 11/03/2025
FDA warns koreafillerexperts.com over unapproved, misbranded injectable botulinum toxin.
What to do: Check whether any botulinum toxin in your practice was bought from koreafillerexperts.com; FDA's November 3, 2025 warning letter says the site sells unapproved, misbranded injectable botulinum toxin.
Source: http://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/korea-filler-experts-718706-11032025
Federal · Primary Source Monitoring · 2026-09-16
Primary Source Monitoring: FDA clarifies policies for compounders as national GLP-1 supply begins to stabilize
FDA updates compounding guidelines as GLP-1 supplies stabilize.
What to do: Semaglutide and tirzepatide are off FDA's drug shortage list and FDA's grace periods for compounding them have ended: for semaglutide on April 22, 2025 (503A pharmacies) and May 22, 2025 (503B), for tirzepatide on February 18 and March 19, 2025. Confirm any compounded GLP-1 you use is not essentially a copy of an approved drug; FDA names semaglutide plus B12 as a combination it may treat as one.
Source: http://www.fda.gov/drugs/drug-alerts-and-statements/fda-clarifies-policies-compounders-national-glp-1-supply-begins-stabilize
Federal · Primary Source Monitoring · 2026-09-04
Primary Source Monitoring: Eli Lilly v. Instant Rx (E.D.N.Y.) — Consent Judgment and Permanent Injunction as to defendants Dispensing Physician Consultants, Inc. d/b/a Ira's Di…
Injunction against suppliers may impact GLP-1 access for med spas.
What to do: If you buy tirzepatide or other Lilly products through Ira's Discount Pharmacy or Total Care Pharmacy, confirm your source: a September 17, 2026 consent judgment in Eli Lilly's lawsuit permanently enjoins those pharmacies.
Source: https://www.courtlistener.com/docket/73584056/153/eli-lilly-and-company-v-instant-rx-inc/
Federal · Primary Source Monitoring · 2026-09-04
Primary Source Monitoring: Med Spa Owner Sentenced to 46 Months in Prison for Performing Thousands of Counterfeit Botox and Filler Injections
Med spa owner sentenced for using counterfeit Botox and fillers.
What to do: Confirm every injector at your practice is licensed to inject and every Botox and filler unit traces to the manufacturer or an authorized distributor. On September 2, 2026 the Massachusetts med spa owner in this case was sentenced to 46 months for injecting counterfeits imported from China and Brazil.
Source: https://www.justice.gov/usao-ma/pr/med-spa-owner-sentenced-46-months-prison-performing-thousands-counterfeit-botox-and
Federal · Primary Source Monitoring · 2026-09-01
Primary Source Monitoring: Peak Performance Peptides - 735127 - 08/24/2026
FDA warns about unapproved peptide products; assess your suppliers.
What to do: Check whether you bought retatrutide (sold as "GLP-3R"), semaglutide, SS-31, PT-141, tesamorelin or bacteriostatic water from pppepz.com; FDA's August 24, 2026 warning letter says these are unapproved new drugs.
Source: http://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/peak-performance-peptides-735127-08242026
Federal · FDA Enforcement · 2026-08-19
FDA recall (Class II): Semaglutide 6.75mg (4.5 mg/mL), 1.5 mL Sterile Multi-Dose Vial, Rx Only, For Subcutaneous Injection Only, Apollo care, …
Recall of semaglutide from Apollo Care due to contamination risk.
What to do: Check your inventory for NDC 71170-821-01 and quarantine any affected stock of semaglutide 6.75mg. Notify patients who may have received this product of the recall and any associated risks.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · Primary Source Monitoring · 2026-08-12
Primary Source Monitoring: Eli Lilly and Company v. Lone Star Peptide Co. LLC (4:26-cv-06562) — District Court, S.D. Texas
Eli Lilly's lawsuit may impact peptide supply chains for med spas.
What to do: If you buy tirzepatide or other peptides from Lone Star Peptide Co., note that Eli Lilly sued it for fraud in federal court in Texas on August 12, 2026. There is no ruling yet.
Source: https://www.courtlistener.com/docket/74513992/eli-lilly-and-company-v-lone-star-peptide-co-llc/
Federal · FDA Enforcement · 2026-05-27
FDA recall (Class II): Liraglutide Injection, 18 mg/3 mL (6 mg/mL), Rx only, Manufactured for: Lupin Pharmaceuticals, Inc., Naples, Fl 34108, …
FDA recalls contaminated Liraglutide Injection.
What to do: Immediately check supplier and lot numbers for Liraglutide Injection. Quarantine any affected products and notify patients as necessary.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · Federal Register · 2026-05-01
FDA / Federal Register Notice: List of Bulk Drug Substances for Which There Is a Clinical Need Under Section 503B of the Federal Food, Drug, and Cosmetic Act
FDA evaluates bulk drug substances; GLP-1 agents may be impacted.
What to do: FDA has proposed not to add semaglutide, tirzepatide or liraglutide to the 503B bulks list, so outsourcing facilities could not compound them from bulk ingredients on that basis if it is finalized. Ask any 503B supplier of these drugs what it will provide if the proposal is finalized; comments closed July 30, 2026 after an extension.
Source: https://www.federalregister.gov/documents/2026/05/01/2026-08552/list-of-bulk-drug-substances-for-which-there-is-a-clinical-need-under-section-503b-of-the-federal
Federal · FDA Enforcement · 2026-04-22
FDA recall (Class II): Semaglutide-Glycine-Cyanocobalamin Injectable, 2.5 mg, 5 mg, 1 MG/ML, 0.5 mL vials, Rx only, Northwest Compounders, Bea…
FDA recalls semaglutide compound over sterility issues.
What to do: Immediately check your supplier for affected lot numbers and quarantine any products. Notify and monitor patients who may have received the recalled compound.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · Primary Source Monitoring · 2026-04-01
Primary Source Monitoring: Utah Licensed Osteopathic Physician Indicted for Allegedly Receiving Misbranded Drugs from China and Selling them to Patients
Indictment of a physician raises concerns for med spas on drug sourcing.
What to do: Do not dispense peptides relabelled in-house from overseas bulk suppliers. The Utah physician indicted in April 2026 bought tirzepatide, semaglutide, retatrutide, BPC-157 and other peptides from China and labelled the vials without the manufacturer's name, which federal law requires.
Source: https://www.justice.gov/usao-ut/pr/utah-licensed-osteopathic-physician-indicted-allegedly-receiving-misbranded-drugs-china
Federal · FDA Enforcement · 2026-03-11
FDA recall (Class II): Tirzepatide Inj, 15mg x 4, Sterile Multi-Dose Vial, Rx only, Nomida, 25055 W Valley Pkwy, Suite 106, Olathe, Ks 66061, …
FDA recalls Tirzepatide Inj over sterility concerns.
What to do: Verify your supplier and lot numbers against the recall notice. Quarantine any affected product immediately and inform patients who may have received this treatment.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · FDA Enforcement · 2026-03-11
FDA recall (Class II): Semaglutide Inj., 2 mg x 5, Sterile Multi-Dose Vial, Rx only, Nomida, 25055 W Valley Pkwy, Suite 106, Olathe, Ks 66061,…
FDA recalls Semaglutide for sterility issues.
What to do: Check your suppliers for the affected lot number and quarantine any impacted products. Additionally, notify patients who received treatments using this GLP-1 and monitor them for any adverse effects.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · FDA Enforcement · 2026-03-11
FDA recall (Class II): Semaglutide, For Rx compounding use only, packaged in a) 1g, NDC 84385-106-01; b) 5g, NDC 84385-106-02; c) 10g, NDC 843…
FDA recalls specific compounded GLP-1 products due to quality issues.
What to do: Immediately check your supplier for affected lot numbers and quarantine any recalled products. Notify and monitor patients who may have been administered these products.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · FDA Enforcement · 2026-01-07
FDA recall (Class II): Wegovy (Semaglutide) Injection, 0.5 mg/0.5 mL, 4 Single-Dose Prefilled Pens, Manufactured by: Novo Nordisk A/S, DK-2880…
FDA recalls Wegovy; med spas must check supplies.
What to do: Review your supplier and lot numbers against the recall notice. Quarantine any affected products and notify patients if they have received this medication.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · FDA Enforcement · 2025-11-05
FDA recall (Class II): Semaglutide Injection, 2.5mg/1mL (2.5 mg/mL), 1mL Multidose Vial, For Subcutaneous Use, Rx Only, Mfd by: ProRx, 619 Jef…
Urgent: FDA recalls compounded semaglutide injection.
What to do: Review your supplies for the recalled lot numbers and quarantine any affected products. Notify patients who may have received this injection and monitor for any adverse effects.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · FDA Enforcement · 2025-11-05
FDA recall (Class II): Tirzepatide Injection, 27 mg/3 mL (9 mg/mL), 3mL Multidose Vial, For Subcutaneous Use, Rx Only, Mfd by: ProRx, 619 Jeff…
Urgent FDA recall of Tirzepatide Injection impacts med spas.
What to do: Check your supplier for the affected lot numbers and quarantine any product from this batch. Notify and monitor patients who have received this injection to ensure their safety.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · FDA Enforcement · 2025-10-15
FDA recall (Class II): Tirzepatide, 60mg/10 mL for Injection, 10mL vial lyophilized, all presentations, GenoGenix, LLC, 2840 Nw 2nd Ave Ste 20…
Important FDA recall on GLP-1 compounded product.
What to do: Check your supplier for the specific lot numbers of the affected product. Quarantine any affected products and notify patients who may have received this treatment.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · FDA Enforcement · 2025-10-15
FDA recall (Class II): Semaglutide with B12 for Injection, all strengths and presentations, GenoGenix, LLC, 2840 Nw 2nd Ave Ste 204 Boca Raton…
FDA recalls GLP-1 product over sterility issues.
What to do: Review your inventory for any GenoGenix GLP-1 products and check lot numbers against the recall notice. Quarantine any affected products and notify your patients of potential risks.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · FDA Enforcement · 2025-09-10
FDA recall (Class II): Semaglutide, 2.5 mg/mL injection, 2 mL., Boothwyn Pharmacy
FDA recalls compounded GLP-1 product for being subpotent.
What to do: Check all supplier and lot numbers against the recall list. Quarantine any affected products and notify patients currently receiving treatment with this compound.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · FDA Enforcement · 2025-08-13
FDA recall (Class II): Tirzepatide + Niacinamide 16.6 mg + 1.0mg/0.5 mL Inj Sol, Inject 0.5 mL (50 units on syringe) subcutaneously, Sterile, …
Important recall for GLP-1 products; take immediate action.
What to do: Verify supplier information and lot numbers against the recall notice. Quarantine any identified products and alert affected patients to monitor for adverse effects.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · FDA Enforcement · 2025-08-13
FDA recall (Class II): Semaglutide + Cyanocobalamin 2.67 mg + 0.25mg/0.5 mL Inj Sol, Inject 0.5 mL (50 units on syringe) subcutaneously, Steri…
FDA recalls compounded GLP-1 product.
What to do: Verify your supplier and lot numbers against the recall notice. Quarantine any affected products and notify patients who may have been administered this product about the recall.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · FDA Enforcement · 2025-07-02
FDA recall (Class II): Tirzepatide Injections, 30mg/mL, pre-filled syringe, Thrive Health Solutions, 88 Inverness, Cir E, Suite A-204, Englewo…
FDA recalls Tirzepatide injections; action needed.
What to do: Check your supplier for affected lot numbers and quarantine any Tirzepatide injections in stock. Notify and monitor patients who may have received this product.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · FDA Enforcement · 2025-07-02
FDA recall (Class II): Semaglutide, 2.5 mg/mL, pre-filled syringe, Thrive Health Solutions, 88 Inverness, Cir E, Suite A-204, Englewood, Co 80…
FDA recalls GLP-1 product over sterility issues.
What to do: Check your supplier and lot numbers for the recalled product immediately. Quarantine affected products and notify any patients who received the injection.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · FDA Enforcement · 2025-05-07
FDA recall (Class II): Wegovy (Semaglutide) injection, 2.4 mg/0.75 mL, 4 Single-Dose Prefilled Pens per Carton, For Subcutaneous Use Only, Rx …
Urgent recall of Wegovy due to temperature abuse risks.
What to do: Check your supplier and lot numbers against the recall list, quarantine any affected products, and notify patients who may have received them of the situation.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-recalls
Federal · Federal Register · 2025-01-07
FDA / Federal Register Notice: Interim Policy on Compounding Using Bulk Drug Substances Under Section 503B of the Federal Food, Drug, and Cosmetic Act; Guidance for Industry; Availability
FDA guidance impacts sourcing for compounding in med spas.
What to do: If a 503B outsourcing facility compounds for your practice, ask it which FDA category each bulk drug substance is in. Under FDA's interim policy published January 7, 2025, the enforcement policy covers only Category 1 substances until FDA decides the 503B bulks list.
Source: https://www.federalregister.gov/documents/2025/01/07/2024-31545/interim-policy-on-compounding-using-bulk-drug-substances-under-section-503b-of-the-federal-food-drug
Federal · Federal Register · 2025-01-07
FDA / Federal Register Notice: Interim Policy on Compounding Using Bulk Drug Substances Under Section 503A of the Federal Food, Drug, and Cosmetic Act; Guidance for Industry; Availability
FDA guidance impacts GLP-1 compounding practices.
What to do: If a 503A pharmacy compounds for your practice, ask it which FDA category each bulk drug substance is in. Under FDA's interim policy published January 7, 2025, the enforcement policy covers only Category 1 substances until FDA finalizes the 503A bulks list.
Source: https://www.federalregister.gov/documents/2025/01/07/2024-31546/interim-policy-on-compounding-using-bulk-drug-substances-under-section-503a-of-the-federal-food-drug

Watch — moving in other states (3)

Not law in this scope. Included because a change in one state is the earliest warning another gets.

TN — national bellwether, not law in this scope · LegiScan · 2026-04-23
TN HB2044: an Act to amend Tennessee Code Annotated, Title 63; Title 68, Chapter 11, Part 2 and Chapter 1042 of the Public Acts of 2024, relative to certified medical assistants.
Tennessee HB 2044 on delegating aesthetic injections to certified MAs.
What to do: Since April 13, 2026, a Tennessee physician assistant working in collaboration with a physician may delegate aesthetic medications (botulinum toxin, fillers and chemical peels) to a certified medical assistant. If you use this, add the delegation to the PA's collaboration protocol and keep each assistant's certification on file.
Source: https://wapp.capitol.tn.gov/apps/Billinfo/Default?BillNumber=HB2044&ga=114
IN — national bellwether, not law in this scope · LegiScan · 2026-03-05
IN SB0282: Compounding drugs; registration of medical spas.
Indiana med spas must register with the licensing board by Jan 1, 2027.
What to do: Medical spas must register with the Indiana medical licensing board by January 1, 2027, and designate a responsible practitioner who ensures compliance with the compounding regulations laid out in section IC 16-42-22.5.
Source: https://iga.in.gov/legislative/2026/bills/senate/282/details
RI — national bellwether, not law in this scope · LegiScan · 2025-06-30
RI H5351: Mandates cosmetic medical procedures be performed by a physician, PA, APRN, or delegated to a qualified non-physician, non-PA or non-APRN under the supervision of a physician, physician assistant, or advanced practice registered nurse.
Major changes in who can perform cosmetic procedures in RI med spas.
What to do: H5351 requires that all cosmetic medical procedures must be performed or delegated by a physician, PA, or APRN under supervision effective immediately — review your practice's personnel qualifications and supervision agreements to ensure compliance.
Source: https://legiscan.com/RI/bill/H5351/2025

Devices & facility (4)

Federal · FDA Device Recall · 2026-09-16
FDA device recall (Class II): Product Name: DermaV Laser System Model/Catalog Number: DermaV Medical laser device that delivers pulsed laser energy a…
FDA recalls DermaV Laser System; check for safety compliance.
What to do: This recall affects the DermaV Laser System from Lutronic Corporation; check your inventory for this model and stop use if affected immediately.
Source: https://www.fda.gov/medical-devices/medical-device-safety/medical-device-recalls
Federal · FDA Warning Letter · 2026-08-25
FDA Warning Letter: Advance-Esthetic LLC (Devices)
FDA says Zemits CrystalFrax Pro, Abigon Pro and Bionexis Lite Pro RF and light body-contouring devices lack required FDA approval or clearance.
What to do: If you own or plan to buy a Zemits CrystalFrax Pro, Abigon Pro or Bionexis Lite Pro, ask the seller for its FDA clearance before treating patients; FDA says these devices have neither premarket approval nor a 510(k).
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/advance-esthetic-llc-729267-08252026
Federal · FDA Device Recall · 2026-03-18
FDA device recall (Class II): Clarity II Laser System; Model No. 1110200210.
FDA recalls Clarity II Laser System for safety concerns.
What to do: Check if you operate the Clarity II Laser System (Model No. 1110200210); if so, stop use immediately and contact Lutronic Corporation for further instructions.
Source: https://www.fda.gov/medical-devices/medical-device-safety/medical-device-recalls
Federal · FDA Device Recall · 2026-01-28
FDA device recall (Class II): Brand Name: Leaseir Product Name: Leaseir Mhr Xcell Model/Catalog Number: Mhr 110-b Software Version: 1.5.0.0 Product D…
Leaseir MHR Xcell laser recalled for safety issues.
What to do: Check if you operate the Leaseir MHR Xcell model and lot. If affected, cease use, contact the manufacturer, and monitor patients accordingly.
Source: https://www.fda.gov/medical-devices/medical-device-recalls

Medications, injectables & compounding (22)

Federal · Primary Source Monitoring · 2026-09-15
Primary Source Monitoring: Hefner v. Rock Valley Compounding Pharmacy, LLC (3:26-cv-01298) — District Court, S.D. Illinois
Legal case filed affecting compounding pharmacy standards.
What to do: No action required: a private lawsuit against Rock Valley Compounding Pharmacy, filed September 15, 2026, has no ruling yet. If you buy from that pharmacy, ask it about the case.
Source: https://www.courtlistener.com/docket/74796068/hefner-v-rock-valley-compounding-pharmacy-llc/
Federal · Primary Source Monitoring · 2026-09-09
Primary Source Monitoring: Human Drug Compounding Policies and Rules
FDA's compounding policy index adds a September 2026 neonatal nutrition guidance.
What to do: No action required: FDA's compounding policies index was updated on September 9, 2026 to add its September 4, 2026 guidance on starter parenteral nutrition for newborns, which does not affect med spas.
Source: http://www.fda.gov/drugs/human-drug-compounding/human-drug-compounding-policies-and-rules
Federal · Primary Source Monitoring · 2026-08-28
Primary Source Monitoring: Agency Information Collection Activities; Proposals, Submissions, and Approvals: Registration of Human Drug Compounding Outsourcing Facilities Under …
FDA proposals may impact compounding practices for med spas.
What to do: No action required unless you run a 503B outsourcing facility: FDA is renewing its registration and fee paperwork for those facilities, with comments due October 30, 2026.
Source: https://www.federalregister.gov/public-inspection/2026-17676/agency-information-collection-activities-proposals-submissions-and-approvals-registration-of-human
Federal · FDA Warning Letter · 2026-08-24
FDA Warning Letter: Peptide Partners, LLC (Drugs)
FDA says Peptide Partners' "research use only" GLP-1s and other injectable peptides are unapproved drugs. Health claims on its own product pages were FDA's evidence that they were intended for human use.
What to do: Check your stock and your staff's suppliers: if anything came from Peptide Partners (peptide.partners), stop using it. FDA found the "research use only" and "not for human or veterinary use" labels did not change what the products were: unapproved drugs.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/peptide-partners-llc-735063-08242026
Federal · FDA Warning Letter · 2026-08-24
FDA Warning Letter: Royal Peptides LLC (Drugs)
FDA says Royal Peptides' "research use only" GLP-1s and other peptides are unapproved drugs. Its weight-loss claims, and the bacteriostatic water, "peptide guide" and "peptide calculator" sold alongside them, were FDA's evidence they were meant for injection in people.
What to do: Check your stock and your staff's suppliers: if anything came from Royal Peptides (royal-peptides.com), stop using it. FDA found the "research use only" and "not for human or animal consumption" labels did not change what the products were: unapproved drugs.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/royal-peptides-llc-734884-08242026
Federal · FDA Warning Letter · 2026-08-24
FDA Warning Letter: Peak Performance Peptides (Drugs)
FDA says Peak Performance Peptides' "research use only" semaglutide, retatrutide and other peptides, and the BAC water sold with them, are unapproved.
What to do: Check your stock and your staff's suppliers: if anything came from Peak Performance Peptides (pppepz.com), stop using it. FDA found the "research use only" and "not for human consumption" labels did not change what the products were: unapproved drugs.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/peak-performance-peptides-735127-08242026
Federal · Primary Source Monitoring · 2026-08-17
Primary Source Monitoring: Illinois Man Charged With Scheme To Impersonate Doctors And Make False Statements To Obtain GLP-1 Medications
Fraud case underlines risks in GLP-1 medication practices.
What to do: No action required: a man was charged in 2026 with impersonating physicians to obtain GLP-1 prescriptions from pharmacies. If a pharmacy asks you to confirm a GLP-1 prescription you did not write, say so and report it.
Source: https://www.justice.gov/usao-sdny/pr/illinois-man-charged-scheme-impersonate-doctors-and-make-false-statements-obtain-glp-1
Federal · Federal Register · 2026-07-30
FDA / Federal Register Notice: Outsourcing Facility Fee Rates for Fiscal Year 2027
FDA fees for outsourcing facilities will impact med spas using compounds.
What to do: No action required unless your practice is registered with FDA as a 503B outsourcing facility. If it is, the FY 2027 annual establishment fee is $7,142 for a small business or $22,074 otherwise, and a reinspection costs $21,427, effective October 1, 2026.
Source: https://www.federalregister.gov/documents/2026/07/30/2026-15342/outsourcing-facility-fee-rates-for-fiscal-year-2027
Federal · Federal Register · 2026-06-26
FDA / Federal Register Notice: List of Bulk Drug Substances for Which There Is a Clinical Need Under Section 503B of the Federal Food, Drug, and Cosmetic Act; Extension of Comment Period
FDA extends comment period on GLP-1 compounding decisions.
What to do: Comments on FDA's proposal not to list semaglutide, tirzepatide or liraglutide on the 503B bulks list closed July 30, 2026. No action required until FDA issues its final determination; if you buy these from a 503B outsourcing facility, ask what it will supply if the proposal is finalized.
Source: https://www.federalregister.gov/documents/2026/06/26/2026-12937/list-of-bulk-drug-substances-for-which-there-is-a-clinical-need-under-section-503b-of-the-federal
Federal · FDA Warning Letter · 2026-06-17
FDA Warning Letter: Herbal Dermals Ltd (Drugs)
Herbal Dermals Ltd received an FDA Warning Letter; verify details.
What to do: Check the FDA public Warning Letters database for details on the violation against Herbal Dermals Ltd, and verify if you source products from this firm.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/warning-letters
Federal · FDA Warning Letter · 2026-06-17
FDA Warning Letter: Herbal Dermals Ltd (Drugs)
FDA issued a Warning Letter to Herbal Dermals Ltd.
What to do: Confirm whether you source products from Herbal Dermals Ltd and check the FDA Warning Letters database for details on the violation.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/warning-letters
Federal · FDA Warning Letter · 2026-06-17
FDA Warning Letter: Wholesale Peptide (Drugs)
FDA says Wholesale Peptide's injectable "Prostamax" and gonadorelin are unapproved new drugs.
What to do: Check whether you source Prostamax, gonadorelin or other injectable peptides from wholesalepeptide.com; FDA has classed these as unapproved drugs.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/wholesale-peptide-729447-06172026
Federal · FDA Warning Letter · 2026-06-17
FDA Warning Letter: Herbal Dermals Ltd (Drugs)
FDA Warning Letter issued to Herbal Dermals Ltd.
What to do: Check FDA's Warning Letters database for the details of the warning against Herbal Dermals Ltd, and verify whether your med spa is sourcing from this firm before proceeding with any orders.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/warning-letters
Federal · FDA Drug Shortages · 2026-06-11
FDA shortage: Liraglutide Injection (Injection) — Currently in Shortage
Liraglutide remains compounded under shortage status.
What to do: Liraglutide is currently in shortage; continue compounding it as permitted. Watch for updates on the shortage status to know when compounding may need to cease.
Source: https://www.fda.gov/drugs/drug-safety-and-availability/drug-shortages
Federal · Primary Source Monitoring · 2026-05-26
Primary Source Monitoring: Agency Information Collection Activities; Proposed Collection; Comment Request; Human Drug Compounding Under Sections 503A and 503B of the Federal Fo…
FDA requests comments on drug compounding information collection.
What to do: No action required: this is FDA's paperwork notice for its compounding information collection. Comments closed July 27, 2026 and it sets no new requirement for practices.
Source: https://www.federalregister.gov/documents/2026/05/26/2026-10372/agency-information-collection-activities-proposed-collection-comment-request-human-drug-compounding
Federal · Primary Source Monitoring · 2026-05-19
Primary Source Monitoring: California Doctor Convicted of $45M Botox Fraud Scheme Targeting Medicare
California doctor convicted in Botox fraud scheme.
What to do: No action required for cash-pay aesthetic Botox: a jury convicted the Los Angeles clinic owner in May 2026 of billing Medicare $45 million for Botox injections that were medically unnecessary or never given.
Source: https://www.justice.gov/opa/pr/california-doctor-convicted-45m-botox-fraud-scheme-targeting-medicare
Federal · FDA Warning Letter · 2026-05-12
FDA Warning Letter: Fresenius Kabi Compounding, LLC (Drugs)
FDA Warning Letter issued to Fresenius Kabi Compounding, LLC.
What to do: Verify whether you source from Fresenius Kabi Compounding, LLC and check the FDA's Warning Letters database for details on the specific violation.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/warning-letters
Federal · Primary Source Monitoring · 2026-04-16
Primary Source Monitoring: Pharmacy Compounding Advisory Committee; Notice of Meeting; Establishment of a Public Docket; Request for Comments-Bulk Drug Substances Nominated for…
Pharmacy Compounding Advisory Committee discusses new bulk substances.
What to do: No action required: FDA's Pharmacy Compounding Advisory Committee met on July 23 and 24, 2026 on substances nominated for the 503A bulks list; watch for FDA's decisions on the substances it reviewed.
Source: https://www.federalregister.gov/documents/2026/04/16/2026-07361/pharmacy-compounding-advisory-committee-notice-of-meeting-establishment-of-a-public-docket-request
Federal · FDA Warning Letter · 2026-03-31
FDA Warning Letter: Mile High Compounds (Drugs)
FDA says the "research-only" semaglutide, tirzepatide and retatrutide sold by Mile High Compounds are unapproved injectable drugs. The firm's own weight-loss dosing guides, shared through its online forum, were FDA's evidence that the products were meant for people.
What to do: Check your stock and your staff's suppliers: if anything came from Mile High Compounds, stop using it. FDA found the "research use only" labels did not change what the products were: unapproved drugs intended for injection in people.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/mile-high-compounds-llc-721600-03312026
Federal · FDA Warning Letter · 2026-03-31
FDA Warning Letter: Gram Peptides (Drugs)
FDA says GRAM Peptides' "research use only" retatrutide and tirzepatide, sold with bacteriostatic water, are unapproved drugs.
What to do: Check whether any retatrutide or tirzepatide in your practice came from grampeptides.com or another "research use only" seller; FDA treats these products as unapproved drugs.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/gram-peptides-721806-03312026
Federal · Primary Source Monitoring · 2026-02-23
Primary Source Monitoring: Agency Information Collection Activities; Submission for Office of Management and Budget Review; Comment Request; Human Drug Compounding Under Sectio…
Comment period open on federal compounding information requirements.
What to do: No action required: this is FDA's paperwork-clearance notice for its compounding information collection. Comments closed March 25, 2026 and it sets no new requirement for practices.
Source: https://www.federalregister.gov/documents/2026/02/23/2026-03448/agency-information-collection-activities-submission-for-office-of-management-and-budget-review
Federal · Federal Register · 2025-07-30
FDA / Federal Register Notice: Outsourcing Facility Fee Rates for Fiscal Year 2026
FDA fees for outsourcing facilities impact compounding.
What to do: No action required unless your practice is registered with FDA as a 503B outsourcing facility. If it is, the FY 2026 annual establishment fee is $6,829 for a small business or $20,726 otherwise, effective October 1, 2025 through September 30, 2026.
Source: https://www.federalregister.gov/documents/2025/07/30/2025-14410/outsourcing-facility-fee-rates-for-fiscal-year-2026

Cross-cutting (18)

Federal · Primary Source Monitoring · 2026-08-25
Primary Source Monitoring: Drug Shortages | Additional News and Information
Stay informed about updated drug shortages affecting aesthetics.
What to do: No action required: FDA updated a drug-shortage news page. Check FDA's drug shortage list for a drug's current status before relying on shortage-based compounding.
Source: http://www.fda.gov/drugs/drug-shortages/drug-shortages-additional-news-and-information
Federal · Primary Source Monitoring · 2026-08-21
Primary Source Monitoring: Compounding and the FDA: Questions and Answers
FDA guidance on compounding released; impact on med spas unclear.
What to do: No action required: FDA's general compounding questions-and-answers page (last revised September 16, 2025) restates that compounded drugs are not FDA-approved. The GLP-1 compounding policy statement is the item that changed practice.
Source: http://www.fda.gov/drugs/human-drug-compounding/compounding-and-fda-questions-and-answers
Federal · Primary Source Monitoring · 2026-08-21
Primary Source Monitoring: Compounding Information for States
FDA issues new compounding guidance; check for local implications.
What to do: No action required: FDA updated its Compounding Information for States page on August 28, 2026. It concerns how state boards report compounding-pharmacy actions to FDA, not requirements for practices.
Source: http://www.fda.gov/drugs/human-drug-compounding/compounding-information-states
Federal · Primary Source Monitoring · 2026-07-31
Primary Source Monitoring: Illinois Man and Indiana Woman Sentenced Respectively to 70 Months and 16 Months in Prison For Selling Unapproved Drugs in Interstate Commerce
Sentencing for selling unapproved drugs serves as a warning.
What to do: Check whether any peptide stock came from Paradigm Peptides; its owner was sentenced to 70 months in 2026 for selling unapproved drugs falsely described as FDA-approved and U.S.-made.
Source: https://www.justice.gov/usao-ndin/pr/illinois-man-and-indiana-woman-sentenced-respectively-70-months-and-16-months-prison
Federal · Primary Source Monitoring · 2026-07-17
Primary Source Monitoring: Wilson v. Lexington Compounding Pharmacy, Inc. (5:26-cv-00273) — District Court, E.D. Kentucky
No immediate changes for med spas from recent court case findings.
What to do: No action required: a private lawsuit against Lexington Compounding Pharmacy, filed July 17, 2026, has no ruling yet. If you buy from that pharmacy, ask it about the case.
Source: https://www.courtlistener.com/docket/73636217/wilson-v-lexington-compounding-pharmacy-inc/
Federal · FDA Warning Letter · 2026-07-08
FDA Warning Letter: Spa De Soleil, Inc. (Drugs)
Water Spa De Soleil uses to make over-the-counter topical products failed testing 51 times from 2024 to 2025. FDA had cited similar problems in 2021.
What to do: If you sell or use over-the-counter topical products made by Spa De Soleil, ask your supplier whether any lots are affected. FDA has not published which products, and the letter says some of what the firm makes may be regulated as cosmetics rather than drugs.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/spa-de-soleil-inc-728508-07082026
Federal · Primary Source Monitoring · 2026-07-01
Primary Source Monitoring: Massachusetts Couple Sentenced to Prison for Importing Misbranded Drugs From China and Selling Them to Customers in U.S. for Performance Enhancing Pu…
A couple was sentenced for selling misbranded drugs in the U.S.
What to do: No action required: this 2026 sentencing concerns a couple who imported misbranded performance-enhancing drugs from China and sold them labelled "For Research Purposes Only". The same label on peptides offered to your practice is a warning sign FDA does not accept.
Source: https://www.justice.gov/usao-ma/pr/massachusetts-couple-sentenced-prison-importing-misbranded-drugs-china-and-selling-them
Federal · Primary Source Monitoring · 2026-06-29
Primary Source Monitoring: Pagan v. Glow Med Spa (1:26-cv-24474) — District Court, S.D. Florida
Americans with Disabilities Act lawsuit filed against a Florida med spa.
What to do: No action required by this case, filed June 29, 2026 under the Americans with Disabilities Act against a Florida med spa as a public accommodation. It is a reminder that accessibility claims reach med spas; check that your premises and website are accessible.
Source: https://www.courtlistener.com/docket/73545400/pagan-v-glow-med-spa/
Federal · FDA Warning Letter · 2026-06-23
FDA Warning Letter: ketaminelab.org (Drugs)
FDA says buyketaminepowderonline.com (formerly ketaminelab.org) sells unapproved, misbranded ketamine powder online.
What to do: Buy ketamine only through licensed, authorized distributors or pharmacies, never from online powder sellers such as this site.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/ket-plug-ketaminelaborg-and-buyketaminepowderonlinecom-728919-06232026
Federal · FDA Warning Letter · 2026-06-17
FDA Warning Letter: Herbal Dermals LLC Fz (Drugs)
FDA says Gotucream, sold online as a balanitis treatment cream, is an unapproved new drug.
What to do: No action for most med spas: this concerns a consumer cream sold online. It matters only if you retail Gotucream.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/herbal-dermals-llc-fz-dba-gotucream-729043-06172026
Federal · Primary Source Monitoring · 2026-05-08
Primary Source Monitoring: Med Spa Owner Pleads Guilty to Performing Illegal Injections Using Unapproved Prescription Drugs
Guilty plea highlights risks of using unapproved injections.
What to do: Buy botulinum toxin only from the manufacturer or an authorized distributor. In this May 2026 plea, unapproved toxin from outside the U.S., injected at a Massachusetts beauty business by someone not licensed to inject, caused numerous cases of botulism.
Source: https://www.justice.gov/usao-ma/pr/med-spa-owner-pleads-guilty-performing-illegal-injections-using-unapproved-prescription
Federal · Primary Source Monitoring · 2026-04-30
Primary Source Monitoring: Advisory Committee; Pharmacy Compounding Advisory Committee; Renewal
Pharmacy Compounding Advisory Committee renewed for continued oversight.
What to do: No action required: FDA renewed the Pharmacy Compounding Advisory Committee's charter through April 25, 2028. The committee advises FDA on which bulk substances may be compounded.
Source: https://www.federalregister.gov/documents/2026/04/30/2026-08378/advisory-committee-pharmacy-compounding-advisory-committee-renewal
Federal · FDA Warning Letter · 2026-04-22
FDA Warning Letter: Active Cosmetics Manufacturing Inc (Drugs)
FDA cites Active Cosmetics Manufacturing for releasing OTC topical drugs after failed microbial tests, including S. aureus.
What to do: If you retail or use OTC topical products made by Active Cosmetics Manufacturing, ask your supplier whether affected batches were distributed and whether a recall is planned.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/active-cosmetics-manufacturing-inc-722408-04222026
Federal · FDA Warning Letter · 2026-04-20
FDA Warning Letter: Foshan Miwei Cosmetics Co., Ltd. (Drugs)
FDA cites Foshan Miwei Cosmetics for releasing OTC drug products without testing active-ingredient strength or microbes.
What to do: If you retail OTC products made by Foshan Miwei Cosmetics, ask your distributor for batch test results before selling more.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/foshan-miwei-cosmetics-co-ltd-722272-04202026
Federal · Primary Source Monitoring · 2026-04-07
Primary Source Monitoring: Med Spa Owner Pleads Guilty to Performing Thousands of Injections Using Counterfeit Products
Med spa owner guilty of using counterfeit injection products.
What to do: Buy Botox, Sculptra and Juvéderm only from the manufacturer or its authorized distributors, and reconcile invoices against units injected. In this April 2026 plea, a Massachusetts med spa owner who was not licensed to inject imported counterfeits from China and Brazil and treated thousands of clients.
Source: https://www.justice.gov/usao-ma/pr/med-spa-owner-pleads-guilty-performing-thousands-injections-using-counterfeit-products
Federal · FDA Warning Letter · 2026-04-02
FDA Warning Letter: Purolea Cosmetics Lab (Drugs)
FDA cites Purolea Cosmetics Lab for insects and filth in its plant and for untested homeopathic drug products.
What to do: If you retail Purolea Cosmetics Lab homeopathic products, ask your supplier which batches were affected before selling more stock.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/purolea-cosmetics-lab-722591-04022026
Federal · FDA Warning Letter · 2026-04-01
FDA Warning Letter: Pure Indulgence Aesthetics (Drugs)
FDA says a Texas med spa administered far more Botox than it bought from AbbVie, and so had sourced toxin from unauthorized suppliers.
What to do: Reconcile your botulinum toxin invoices against units administered, and confirm every vial came from the manufacturer or an authorized distributor. FDA treats a med spa that administers prescription drugs as a DSCSA dispenser, bound to buy only from authorized trading partners.
Source: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/pure-indulgence-aesthetics-723267-04012026
Federal · Primary Source Monitoring · 2025-12-18
Primary Source Monitoring: Doctor Indicted for Orchestrating $45M Botox Fraud Scheme Targeting Medicare
Doctor indicted in $45M Botox fraud scheme targeting Medicare.
What to do: No action required for cash-pay aesthetic Botox: this December 2025 indictment concerns a Los Angeles clinic that billed Medicare $45 million for Botox injections that were medically unnecessary or never given.
Source: https://www.justice.gov/opa/pr/doctor-indicted-orchestrating-45m-botox-fraud-scheme-targeting-medicare

Marketing & advertising (1)

Federal · FTC Enforcement · 2026-06-12
FTC Files Contempt Motion Against Amare Global and Three Individuals Over Unsubstantiated Health Claims
FTC targets deceptive health claims affecting aesthetic practices.
What to do: Review all marketing materials for accuracy and ensure that any health claims made are properly substantiated. Consider conducting a compliance audit to align with FTC guidelines.
Source: https://www.ftc.gov/news-events/news/press-releases/2026/06/ftc-files-contempt-motion-against-amare-global-three-individuals-over-unsubstantiated-health-claims

Scope of practice & delegation (2)

Federal · Primary Source Monitoring · 2025-12-12
Primary Source Monitoring: Med Spa Owner Agrees to Plead Guilty to Performing Illegal Injections Using Unapproved Prescription Drugs
Legal repercussions for med spas using unapproved injection drugs.
What to do: Buy botulinum toxin only from the manufacturer or an authorized distributor. This December 2025 filing concerns unapproved toxin from outside the U.S., injected at a Massachusetts beauty business by someone not licensed to inject, that caused numerous cases of botulism.
Source: https://www.justice.gov/usao-ma/pr/med-spa-owner-agrees-plead-guilty-performing-illegal-injections-using-unapproved
Federal · Primary Source Monitoring · 2025-12-03
Primary Source Monitoring: Southern New Mexico Medical Spa Operator Settles Allegations of Controlled-Substance Recordkeeping Violations
Med spa operator faces penalties for recordkeeping violations.
What to do: If your practice holds controlled substances, confirm your biennial DEA inventory records the count and form on hand and the date each shipment arrived. A New Mexico med spa operator settled in December 2025 after failing to account for 240 missing doses.
Source: https://www.justice.gov/usao-nm/pr/southern-new-mexico-medical-spa-operator-settles-allegations-controlled-substance

2 · Standing state rules

48 cited rules across 1 state

The rules that stand today — not what changed this week. Each is quoted from, and linked to, its primary source, with the date we last verified it. Reference and monitoring, not legal advice.

What this brief covers, state by state

on_record · printed here: Texas (48) — cited rules printed below, each linked to its primary source.

Texas

Physician supervision & delegation

Cosmetic injections, dermal fillers and cosmetic laser use are medical acts a Texas physician may delegate to a qualified, properly trained person under supervision — with a written order that identifies the physician and sets patient-screening criteria. ⚠️ laser hair removal sits outside that route entirely: it is separately licensed under the Health & Safety Code, on a tiered certificate.

A Texas physician may delegate a medical act — including cosmetic injections, dermal fillers, and cosmetic laser use — to a qualified, properly trained person acting under the physician’s supervision, where a reasonable and prudent physician would find it consistent with sound medical judgment. The delegating physician remains responsible for the delegated act.
Tex. Occ. Code §157.001 · verified 2026-07-26 https://tcss.legis.texas.gov/resources/OC/htm/OC.157.htm
The Texas Medical Board classifies nonsurgical medical cosmetic procedures — including the injection of medications or substances for cosmetic purposes and the use of a prescription medical device for cosmetic purposes — as the practice of medicine that may be properly delegated and supervised.
22 TAC §169.25 · verified 2026-07-26 https://texas-sos.appianportalsgov.com/rules-and-meetings?interface=VIEW_TAC&title=22&part=9&chapter=169read at Cornell Legal Information Institute: https://www.law.cornell.edu/regulations/texas/22-Tex-Admin-Code-SS-169-25
The delegating physician must review, approve, or develop a written order for the delegated procedure that identifies the physician, sets patient-screening criteria, describes appropriate care, and provides procedures for handling common complications.
22 TAC §169.27 · verified 2026-07-26 https://texas-sos.appianportalsgov.com/rules-and-meetings?interface=VIEW_TAC&title=22&part=9&chapter=169read at Cornell Legal Information Institute: https://www.law.cornell.edu/regulations/texas/22-Tex-Admin-Code-SS-169-27
Laser hair removal is separately licensed in Texas and sits OUTSIDE the medical-delegation route above. No person may perform or attempt to perform laser hair removal — the use of a laser or pulsed light device for nonablative hair removal — unless they hold the appropriate certificate from the Texas Department of Licensing and Regulation. That certificate authorizes nonablative cosmetic laser hair removal ONLY: it does not authorize the holder to diagnose, treat, or offer to treat any illness, disease, injury, defect or deformity, and the holder must disclose that limitation in writing to every client and prospective client.
Tex. Health & Safety Code §401.504 · verified 2026-08-17 https://tcss.legis.texas.gov/resources/HS/htm/HS.401.htm
The certificate is tiered. A laser hair removal technician certificate is the base rung; a senior laser hair removal technician must meet the technician requirements and have supervised at least 100 laser hair removal procedures, audited by a certified laser hair removal professional; and a certified laser hair removal professional must meet the senior technician requirements, hold certification from a department-recognized certifying agency, and pass a department examination. A certified professional performs laser hair removal under a protocol established with a consulting physician.
Tex. Health & Safety Code §401.505, §401.506 · verified 2026-08-17 https://tcss.legis.texas.gov/resources/HS/htm/HS.401.htm
TDLR's medspa services chart lists each service offered at a med spa alongside the agency that regulates it. The entry reads “Microneedling (Platelet-rich plasma (PRP) injections/Vampire facials) Texas Medical Board”, placing that service under the Texas Medical Board rather than under a TDLR license.
TDLR, MedSpas at a Glance, Service/Who Regulates chart (Microneedling) · verified 2026-09-20 https://www.tdlr.texas.gov/media/pdf/Medspas-at-a-Glance.pdf
⚠️ Texas draws the esthetician line at living tissue, and microneedling is a device that punctures it. tdlr states the test twice. On exfoliation: a treatment that “does not pierce the dermal layer of skin” is within scope, while treatments that “contact or penetrate the dermis (living tissue) DO not fall within the scope of an esthetician or cosmetology operator license and must be administered or delegated by a physician.” On peels, the same line: those that “penetrate the dermis (living tissue) and are considered medical procedures regulated by the Texas medical board.” tdlr’s guidance does not name microneedling — it states a depth test, and a needle depth is the operator’s setting.
TDLR Barbering and Cosmetology — Medical Spas guidance · verified 2026-09-02 https://www.tdlr.texas.gov/barbering-and-cosmetology/medical-spas.htm
And the scope description carries a parenthetical worth reading: an esthetician may “administer facial treatments, (please note that these treatments DO not include injectables, fillers and other types of medical-type procedures that require the use of needles).” TDLR’s express out-of-scope list names hypodermic needles used to inject; it does not address a needling device that injects nothing.
TDLR Barbering and Cosmetology — Medical Spas guidance · verified 2026-09-02 https://www.tdlr.texas.gov/barbering-and-cosmetology/medical-spas.htm
Beginning September 1, 2025, HB 3749 limits both the ordering and administration of elective IV hydration or vitamin infusions to physicians, advanced practice registered nurses, and registered nurses acting under a physician's delegation; licensed vocational nurses, emergency medical technicians, paramedics and unlicensed persons may not be delegated these services.
Texas BON Position Statement 15.3 (LVNs engaging in intravenous therapy — elective IV hydration after HB 3749) · verified 2026-09-08 https://www.bon.texas.gov/pdfs/practice_dept_pdfs/position_statements_pdfs/BON%20Position%20Statements%202026.pdf

Good-faith examination

Before a delegated cosmetic act Texas requires a practitioner-patient relationship to be established — by a physician, or by a PA or APRN acting under the physician’s delegation — and an adequate medical RECORD to be maintained. A physician, PA or APRN must be onsite or immediately available, and at least one person trained in basic life support must be present.

Before a delegated cosmetic act, a practitioner-patient relationship must be established by a physician, or by a PA or APRN acting under the physician’s delegation, and an adequate medical record must be maintained. The identity and title of the person who will perform the act must be disclosed to the patient.
22 TAC §169.26 · verified 2026-07-26 https://texas-sos.appianportalsgov.com/rules-and-meetings?interface=VIEW_TAC&title=22&part=9&chapter=169read at Cornell Legal Information Institute: https://www.law.cornell.edu/regulations/texas/22-Tex-Admin-Code-SS-169-26
A physician, PA, or APRN must be onsite during the procedure or immediately available for emergency consultation, and at least one person trained in basic life support must be present while the patient is onsite.
22 TAC §169.26 · verified 2026-07-26 https://texas-sos.appianportalsgov.com/rules-and-meetings?interface=VIEW_TAC&title=22&part=9&chapter=169read at Cornell Legal Information Institute: https://www.law.cornell.edu/regulations/texas/22-Tex-Admin-Code-SS-169-26
For purposes of the requirement of a practitioner-patient relationship for a valid prescription, a valid practitioner-patient relationship is present between a practitioner providing a telemedicine medical service and a patient receiving the service as long as the practitioner complies with the standard of care described in Section 111.007 and has a preexisting relationship with the patient, communicates under a call coverage agreement, or provides the service through synchronous audiovisual interaction, asynchronous store and forward technology using clinically relevant images or the relevant clinical records, or another method that allows the practitioner to use the clinical information the standard of care requires.
Tex. Occ. Code §111.005(a) · verified 2026-09-08 https://tcss.legis.texas.gov/resources/OC/htm/OC.111.htm

Ownership & corporate practice of medicine

Texas follows the corporate-practice-of-medicine doctrine, derived from the Medical Practice Act’s licensure requirement rather than a single titled statute.

⚠️ in Texas paying for patients is a crime, not a board matter. “a person commits an offense if the person knowingly offers to pay or agrees to accept, directly or indirectly, overtly or covertly any remuneration in cash or in kind or any benefit or commission to or from another for securing or soliciting a patient or patronage” for or from a person licensed by a state health care regulatory agency. “PATRONAGE” is wider than patients, and “any benefit” is wider than money.
Tex. Occ. Code § 102.001(a) · verified 2026-09-02 https://tcss.legis.texas.gov/resources/OC/htm/OC.102.htm
And the penalty escalates. The offense is a class a misdemeanor, rising to a felony of the third degree where the person “has previously been convicted of an offense under this section” or “was employed by a federal, state, or local government at the time of the offense”. ⚠️ this section was amended effective 1 SEPTEMBER 2025 by H.B. 4454 — recent enough that older guidance may not reflect it.
Tex. Occ. Code § 102.001(b)–(c) · verified 2026-09-02 https://tcss.legis.texas.gov/resources/OC/htm/OC.102.htm
Two doors are left open, and both matter to a med spa. First, § 102.001 “permits any payment, business arrangement, or payment practice permitted by 42 u.s.c. section 1320a-7b(b) or any regulation adopted under that law” — the federal anti-kickback safe harbors carry directly into Texas criminal law. Second, it “does not prohibit advertising, unless the advertising is: (1) false, misleading, or deceptive; (2) not readily subject to verification, if the advertising claims professional superiority or the performance of a professional service in a superior manner”, or is prohibited under chapter 164 of the Health and Safety Code.
Tex. Occ. Code §§ 102.003–102.004 · verified 2026-09-02 https://tcss.legis.texas.gov/resources/OC/htm/OC.102.htm
A person may not practice medicine in Texas unless licensed by the Texas Medical Board under Subtitle B.
Tex. Occ. Code §155.001 · verified 2026-07-26 https://tcss.legis.texas.gov/resources/OC/htm/OC.155.htm
Because only a licensed person may practice medicine and no provision authorizes a general business corporation to hold that license, Texas follows the corporate-practice-of-medicine doctrine: an unlicensed individual or ordinary corporation cannot practice medicine or employ physicians in a way that controls their medical judgment.
Tex. Occ. Code ch. 155 (doctrine derived from the licensure requirement; no titled CPOM statute) · verified 2026-07-26 https://tcss.legis.texas.gov/resources/OC/htm/OC.155.htm
One recognized structure is a Board-certified nonprofit health organization (a “5.01(a)” corporation) that is organized solely by Board-licensed physicians.
Tex. Occ. Code §162.001 · verified 2026-07-26 https://tcss.legis.texas.gov/resources/OC/htm/OC.162.htm
Even a certified organization may not interfere with, control, or otherwise direct a physician’s professional judgment.
Tex. Occ. Code §162.0021 · verified 2026-07-26 https://tcss.legis.texas.gov/resources/OC/htm/OC.162.htm

RN / NP scope for injectables

A registered nurse who is not an APRN (and an LVN) may not perform medical diagnosis or prescribe, but may carry out a delegated medical act — such as administering a cosmetic injection ordered by an appropriately licensed practitioner — when the Board of Nursing’s criteria are met: documented competency/education, written policies and guidelines, an order from an appropriate licensed practitioner, and available medical and nursing support.
Tex. BON Position Statement 15.11 · verified 2026-07-26 https://www.bon.texas.gov/pdfs/practice_dept_pdfs/position_statements_pdfs/BON%20Position%20Statements%202026.pdf
For laser therapy performed by RNs or LVNs, the Board of Nursing directs nurses to the Texas Medical Board’s delegation rule for nonsurgical cosmetic procedures and to the Health & Safety Code’s laser provisions.
Tex. BON Position Statement 15.9 · verified 2026-07-26 https://www.bon.texas.gov/pdfs/practice_dept_pdfs/position_statements_pdfs/BON%20Position%20Statements%202026.pdf
The APRN acts independently, under the delegated authority of a physician and/or in collaboration with other health care professionals in the delivery of health care services, and APRNs utilize mechanisms, including protocols, prescriptive authority agreements, or other written authorization, that provide them with the authority to provide medical aspects of care, including the ordering of dangerous drugs, controlled substances, or devices that bear a federal prescription legend.
Texas BON Position Statement 15.18 (Nurses Carrying out Orders from Advanced Practice Registered Nurses) · verified 2026-09-08 https://www.bon.texas.gov/pdfs/practice_dept_pdfs/position_statements_pdfs/BON%20Position%20Statements%202026.pdf
Texas defines the physician assistant’s practice as delegated practice, and the injection sits inside it. “The practice of a physician assistant includes providing medical services delegated by a supervising physician that are within the education, training, and experience of the physician assistant.” The enumerated services include “ordering or performing diagnostic and therapeutic procedures” and “prescribing or ordering a drug or device as provided by Subchapter B” of Chapter 157. The relationship is stated as agency: “A physician assistant is the agent of the physician assistant’s supervising physician for any medical services that are delegated by that physician” and that “are delineated by protocols, practice guidelines, or practice directives established by the supervising physician”.
Tex. Occ. Code § 204.202(a)-(b), (e) (Scope of practice) · verified 2026-09-08 https://tcss.legis.texas.gov/resources/OC/htm/OC.204.htm
Prescribing takes a separate written instrument, and the physician’s side of it is capped. “a physician may delegate to an advanced practice registered nurse or physician assistant, acting under adequate physician supervision, the act of prescribing or ordering a drug or device as authorized through a prescriptive authority agreement” between them. “the combined number of advanced practice registered nurses and physician assistants with whom a physician may enter into a prescriptive authority agreement may not exceed seven”, or their full-time equivalent — a limit that does not apply to a practice serving a medically underserved population or to a facility-based practice.
Tex. Occ. Code § 157.0512(a), (c)-(d) (Prescriptive authority agreement) · verified 2026-09-08 https://tcss.legis.texas.gov/resources/OC/htm/OC.157.htm

Disciplinary landscape

Texas keeps two tracks apart, and a med spa can be on both. Against an unlicensed operator the exposure is criminal and administrative at once: practicing medicine without a license is a third-degree felony with each day a separate offense, holding out as entitled to practice — by advertising, title or stationery — is itself an offense reachable against a business entity, and the Texas Medical Board may issue a cease-and-desist order against an unlicensed person it believes is practicing medicine. Against a licensee the board may refuse a license or take disciplinary action for a prohibited practice, for a felony conviction or a misdemeanor of moral turpitude, or for failing to practice medicine in an acceptable professional manner consistent with public health and welfare. Two enumerated forms of unprofessional or dishonorable conduct are the ones a med spa meets first: failing to supervise adequately the activities of those acting under the physician’s supervision, and delegating medical responsibility to a person the physician knows or has reason to know is not qualified by training, experience, or licensure. A false, misleading or deceptive advertising statement is a prohibited practice in its own right. These claims survey chapters 164 and 165 of the Occupations Code; they do not survey the board’s own rules on sanctions, and no named med-spa enforcement case is cited here.

Practicing medicine without a license in Texas is a third-degree felony, and each day of unlicensed practice is a separate offense.
Tex. Occ. Code §165.152 · verified 2026-07-26 https://tcss.legis.texas.gov/resources/OC/htm/OC.165.htm
The Texas Medical Board may issue a cease-and-desist order against an unlicensed person it believes is practicing medicine.
Tex. Occ. Code §165.052 · verified 2026-07-26 https://tcss.legis.texas.gov/resources/OC/htm/OC.165.htm
Holding out — through advertising, titles, or stationery — as entitled to practice medicine without a license is a criminal offense, reachable against an individual or a business entity.
Tex. Occ. Code §165.156 · verified 2026-07-26 https://tcss.legis.texas.gov/resources/OC/htm/OC.165.htm
Two enumerated forms of unprofessional or dishonorable conduct likely to deceive or defraud the public reach a med spa directly. One is a physician who “fails to supervise adequately the activities of those acting under the supervision of the physician”. The other is a physician who “delegates professional medical responsibility or acts to a person if the delegating physician knows or has reason to know that the person is not qualified by training, experience, or licensure to perform the responsibility or acts”.
Tex. Occ. Code § 164.053(a)(8)-(9) · verified 2026-09-08 https://tcss.legis.texas.gov/resources/OC/htm/OC.164.htm
The board may refuse to admit a person to its examination or refuse to issue a license to practice medicine and may take disciplinary action against a person who commits an act prohibited under the prohibited-practices section, who is convicted of a felony or of a misdemeanor involving moral turpitude, or who “fails to practice medicine in an acceptable professional manner consistent with public health and welfare”.
Tex. Occ. Code § 164.051(a) · verified 2026-09-08 https://tcss.legis.texas.gov/resources/OC/htm/OC.164.htm
A physician commits a prohibited practice by committing “unprofessional or dishonorable conduct that is likely to deceive or defraud the public”, and separately by using “an advertising statement that is false, misleading, or deceptive”.
Tex. Occ. Code § 164.052(a)(5)-(6) · verified 2026-09-08 https://tcss.legis.texas.gov/resources/OC/htm/OC.164.htm

Med-spa registration & licensing

⚠️ Texas is the permissive end of this corpus on compounded stock: a pharmacy MAY dispense and deliver a reasonable quantity of a compounded drug to a practitioner for office use, with no commercial-availability condition — but injectables are sterile preparations, and a pharmacy may not compound and dispense one unless it holds a separate sterile-compounding license. Texas otherwise licenses the laser hair removal facility: its own license, separately for each location, plus a written contract with a consulting physician to set and audit its protocols. ⚠️ the carve-outs decide whether that reaches you — facilities owned or operated by a physician for the practice of medicine, licensed hospitals and hospital-owned clinics are outside it.

⚠️ Texas permits office-use compounding outright, which few states DO. “A pharmacy may dispense and deliver a reasonable quantity of a compounded drug to a practitioner for office use by the practitioner in accordance with this chapter.” There is no commercial-availability condition and no patient-specific prescription requirement — the limit is the phrase “reasonable quantity”.
Tex. Occ. Code § 562.152 · verified 2026-09-02 https://tcss.legis.texas.gov/resources/OC/htm/OC.562.htm
The conditions sit on the pharmacy, not the practice. To dispense and deliver a compounded drug for office use a pharmacy must verify the source of the raw materials; comply with applicable united states pharmacopoeia guidelines including the testing requirements, and with HIPAA; comply with all applicable competency and accrediting standards as determined by the board; and comply with board rules “including rules regarding the reporting of adverse events by practitioners and recall procedures for compounded products”. That last clause reaches back to the practice: adverse-event reporting is a practitioner duty imposed through the pharmacy’s rules.
Tex. Occ. Code § 562.153 · verified 2026-09-02 https://tcss.legis.texas.gov/resources/OC/htm/OC.562.htm
⚠️ and injectables are sterile, which is its own license. “a pharmacy may not compound and dispense a sterile preparation unless the pharmacy holds a license as required by board rule.” Compounded semaglutide is a sterile preparation, so the office-use permission above runs only through a pharmacy holding that separate sterile-compounding license — the first thing to ask a supplier for.
Tex. Occ. Code § 562.156(a) · verified 2026-09-02 https://tcss.legis.texas.gov/resources/OC/htm/OC.562.htm
The sterile-compounding pharmacy carries two clocks. It shall notify the board “IMMEDIATELY of any adverse effects reported to the pharmacy or that are known by the pharmacy to be potentially attributable to a sterile preparation compounded by the pharmacy”, and “NOT LATER THAN 24 hours after the pharmacy issues a recall” for such a preparation. A practice that has administered from a recalled lot will hear about it on that timetable.
Tex. Occ. Code § 562.156(b) · verified 2026-09-02 https://tcss.legis.texas.gov/resources/OC/htm/OC.562.htm
A person may not operate a laser hair removal facility without a license issued for that facility, and a separate license is required for each location. The requirement does not apply to a facility owned or operated by a physician for the practice of medicine, to a licensed hospital, or to a clinic owned or operated by a licensed hospital.
Tex. Health & Safety Code §401.510 · verified 2026-08-17 https://tcss.legis.texas.gov/resources/HS/htm/HS.401.htm
A laser hair removal facility must hold a written contract with a consulting physician to establish the protocols for the services it provides and to audit those protocols and the facility’s operations. The facility must document that contractual relationship with the department, and the consulting physician must be available for emergency consultation as the circumstances require.
Tex. Health & Safety Code §401.519 · verified 2026-08-17 https://tcss.legis.texas.gov/resources/HS/htm/HS.401.htm
💰 Texas prices the premises by type, and late renewal is the expensive part. tdlr publishes “Initial Application Fees” of “$50 for Practitioners (Class A Barbers, Cosmetology Operators & Specialty license holders)”, “$70 for Mini-Establishments” and “$78 for Barbering & Cosmetology (“Full-Service”) Establishment, Mobile & Specialty Establishments”. Practitioner renewal runs “$50 for On-time Renewals”, “$75 for Late Renewals (expired less than 18 months)”.
TDLR Barbering and Cosmetology — Fee Changes Effective 09/01/2023 (accessed 2 September 2026) · verified 2026-09-02 https://www.tdlr.texas.gov/barbering-and-cosmetology/feechanges.htm
And the term matters for cash-flow planning: “Establishment licenses are valid for two years from the date of issue.” The same page prices the three premises types side by side — “Establishment License … $78”, “Specialty Establishment License … $78” and “Mini-Establishment License … $70” — and warns that “all requirements must be met within one year of the date the application is received, or the application will be deemed void.”
TDLR — Apply for a Barbering or Cosmetology Establishment License (accessed 2 September 2026) · verified 2026-09-02 https://www.tdlr.texas.gov/barbering-and-cosmetology/establishments/apply.htm
⚠️ an out-of-state pharmacy shipping into Texas needs a Texas license, and the rule reaches supply under chapter 562’s subchapter d. “a pharmacy located in another state may not ship, mail, or deliver to this state a prescription drug or device dispensed under a prescription drug order, or dispensed or delivered as authorized by Subchapter D” of Chapter 562 “unless the pharmacy is licensed by the board or is exempt under Section 560.004” — and that exemption is for a pharmacy that “restricts to isolated transactions the pharmacy's dispensing of a prescription drug or device to a resident of this state.” A Texas practice buying from an out-of-state compounder should ask for the Texas license number.
Tex. Occ. Code §§ 560.001(b), 560.004 · verified 2026-09-15 https://tcss.legis.texas.gov/resources/OC/htm/OC.560.htm
A Texas physician may supply for a patient’s immediate needs, not run a dispensary. “a physician licensed under this subtitle may supply a patient with any drug, remedy, or clinical supply necessary to meet the patient's immediate needs”, and the section “does not permit a physician to operate a retail pharmacy without complying with Chapter 558”. Keeping an office supply of dangerous drugs to dispense, and being reimbursed for their cost without a pharmacy license, is allowed only where § 158.003 applies: “a county with a population of 5,000 or less, or in a municipality or an unincorporated town with a population of less than 2,500, that is within a 15-mile radius of the physician's office and in which a pharmacy is not located.”
Tex. Occ. Code §§ 158.001, 158.003 · verified 2026-09-15 https://tcss.legis.texas.gov/resources/OC/htm/OC.158.htm

Advertising rules

Texas regulates med-spa advertising through the Medical Board’s physician advertising rules, and several bite hardest on a med spa: a TESTIMONIAL is deemed misleading without both a credentials disclaimer and disclosure of compensation; models or actors must be identified as such; an undisclosed medical directorship at a non-primary location is deemed misleading; patients must consent before their photographs are used — the before-and-after gallery rule; and a copy of every advertisement must be kept for two years.

Advertising about the practice of medicine, professional credentials and qualifications is permitted, but the information in the advertisement may not be false, deceptive or misleading.
22 TAC §164.3(a) · verified 2026-08-17 https://texas-sos.appianportalsgov.com/rules-and-meetings?interface=VIEW_TAC&title=22&part=9&chapter=164read at Cornell Legal Information Institute: https://www.law.cornell.edu/regulations/texas/22-Tex-Admin-Code-SS-164-3
Failing to disclose a medical directorship, or the supervision of or delegation to non-physicians, at a location that is not the physician’s primary practice location and where care is delivered under standing orders and protocols, is itself deemed false, deceptive or misleading advertising. This is the provision that reaches the common med-spa arrangement in which the supervising physician is rarely on site.
22 TAC §164.3(b)(8) · verified 2026-08-17 https://texas-sos.appianportalsgov.com/rules-and-meetings?interface=VIEW_TAC&title=22&part=9&chapter=164read at Cornell Legal Information Institute: https://www.law.cornell.edu/regulations/texas/22-Tex-Admin-Code-SS-164-3
A testimonial is deemed false, deceptive or misleading unless it carries both a disclaimer or warning as to the credentials of the person giving it and a disclosure of any compensation provided in exchange for it.
22 TAC §164.3(b)(3) · verified 2026-08-17 https://texas-sos.appianportalsgov.com/rules-and-meetings?interface=VIEW_TAC&title=22&part=9&chapter=164read at Cornell Legal Information Institute: https://www.law.cornell.edu/regulations/texas/22-Tex-Admin-Code-SS-164-3
Failing to explicitly identify individuals appearing in advertising as models or actors rather than actual patients is deemed false, deceptive or misleading.
22 TAC §164.3(b)(4) · verified 2026-08-17 https://texas-sos.appianportalsgov.com/rules-and-meetings?interface=VIEW_TAC&title=22&part=9&chapter=164read at Cornell Legal Information Institute: https://www.law.cornell.edu/regulations/texas/22-Tex-Admin-Code-SS-164-3
Every physician is responsible for the form and content of any advertisement for their individual or group practice, and is deemed to have reviewed and approved every such advertisement — whether or not they in fact saw it before it ran.
22 TAC §164.2(a) · verified 2026-08-17 https://texas-sos.appianportalsgov.com/rules-and-meetings?interface=VIEW_TAC&title=22&part=9&chapter=164read at Cornell Legal Information Institute: https://www.law.cornell.edu/regulations/texas/22-Tex-Admin-Code-SS-164-2
Patients must consent before any use of photographs or other representations of them in advertising by a physician, a practice, or an entity — which is the rule a before-and-after gallery turns on.
22 TAC §164.2(b) · verified 2026-08-17 https://texas-sos.appianportalsgov.com/rules-and-meetings?interface=VIEW_TAC&title=22&part=9&chapter=164read at Cornell Legal Information Institute: https://www.law.cornell.edu/regulations/texas/22-Tex-Admin-Code-SS-164-2
A recording or copy of any advertisement must be retained by the physician for two years from the last date it was communicated.
22 TAC §164.2(c) · verified 2026-08-17 https://texas-sos.appianportalsgov.com/rules-and-meetings?interface=VIEW_TAC&title=22&part=9&chapter=164read at Cornell Legal Information Institute: https://www.law.cornell.edu/regulations/texas/22-Tex-Admin-Code-SS-164-2
Whenever the consumer protection division has reason to believe that any person is engaging in, has engaged in, or is about to engage in any act or practice declared unlawful by the Deceptive Trade Practices subchapter, and that proceedings would be in the public interest, the division may bring an action in the name of the state to restrain the practice by temporary restraining order, temporary injunction, or permanent injunction.
Tex. Bus. & Com. Code §17.47(a) · verified 2026-09-08 https://tcss.legis.texas.gov/resources/BC/htm/BC.17.htm

Texas library current as of Sep 20, 2026.

3 · Compliance review checklist

Confirm each with your counsel / medical director. State rules vary and change.

Good-Faith Exam (GFE)

☐A qualified provider performs a good-faith exam before the first treatment, per your state’s standard.
☐The examiner is authorized in your state to order the specific treatment.
☐If the GFE is via telehealth, it meets your state’s telehealth + establish-the-relationship rules.
☐The exam is documented in the patient record (history, contraindications, the order).
☐A re-exam cadence for repeat / changed treatments is defined and followed.

Medical Director & ownership

☐A licensed physician medical director is engaged to the extent your state requires.
☐The MD agreement defines scope, supervision, chart-review cadence, and availability for adverse events.
☐Ownership / management structure complies with your state’s corporate-practice-of-medicine rules (MSO if applicable).
☐The MD’s actual involvement matches what’s on paper (not a “rent-a-director” arrangement).

Delegation & supervision

☐Each treatment is performed by a provider authorized in your state (MD / NP / PA / RN / aesthetician scope).
☐Injectable (neuromodulator / filler) delegation + supervision meets your state’s requirements.
☐Laser / energy-device delegation matches your state (some require physician or NP involvement).
☐Standing orders / protocols are signed, current, and specific to the treatments offered.
☐The supervision level required (direct / indirect / general) is documented and actually met.

Advertising & claims (FTC)

☐No “FDA-approved” language for compounded products — they are not FDA-approved.
☐Weight-loss / efficacy claims are backed by competent, reliable evidence (the FTC standard).
☐Compounded GLP-1s are named accurately (“compounded semaglutide,” not “Ozempic” / “Wegovy”).
☐Before/after photos are genuine, consented, and not cherry-picked or retouched to mislead.
☐No guarantees of results; testimonials disclose any material connection (FTC endorsement rules).

4 · Background record

Single-shipment import refusals, routine inspection citations, and board or agency web notices that carry no specific instruction — published and source-linked, but not scored as affecting practice. No action is implied. Showing the 20 most recent of 350.

Federal · FDA Import Refusal · 2026-09-16FDA import refusal: Implant, Dermal, Collagen for Aesthetic Use (South Korea)
Federal · FDA Import Refusal · 2026-09-16FDA import refusal: Implant, Dermal, Collagen for Aesthetic Use (France)
Federal · FDA Import Refusal · 2026-09-16FDA import refusal: Lidocaine (South Korea)
Federal · FDA Import Refusal · 2026-09-16FDA import refusal: Botox (onabotulinumtoxinA) (Ireland)
Federal · FDA Import Refusal · 2026-09-16FDA import refusal: Botox (onabotulinumtoxinA) (Vietnam)
Federal · FDA Import Refusal · 2026-09-16FDA import refusal: Botox (onabotulinumtoxinA) (South Korea)
Federal · FDA Import Refusal · 2026-09-16FDA import refusal: Implant, Dermal, Collagen for Aesthetic Use (Sweden)
Federal · FDA Import Refusal · 2026-09-16FDA import refusal: Botox (onabotulinumtoxinA) (South Korea)
Federal · FDA Import Refusal · 2026-09-16FDA import refusal: Daxxify (daxibotulinumtoxinA)-LANM (Vietnam)
Federal · FDA Import Refusal · 2026-09-16FDA import refusal: Lidocaine (South Korea)
Federal · FDA Import Refusal · 2026-09-16FDA import refusal: Implant, Dermal, Collagen for Aesthetic Use (South Korea)
Federal · FDA Import Refusal · 2026-09-16FDA import refusal: Botox (onabotulinumtoxinA) (South Korea)
Federal · FDA Import Refusal · 2026-09-16FDA import refusal: Implant, Dermal, Collagen for Aesthetic Use (South Korea)
Federal · FDA Import Refusal · 2026-09-16FDA import refusal: Implant, Dermal, Collagen for Aesthetic Use (South Korea)
Federal · FDA Import Refusal · 2026-09-15FDA import refusal: Implant, Dermal, Collagen for Aesthetic Use (South Korea)
Federal · FDA Import Refusal · 2026-09-15FDA import refusal: Implant, Dermal, Collagen for Aesthetic Use (Canada)
Federal · FDA Import Refusal · 2026-09-14FDA import refusal: Implant, Dermal, Collagen for Aesthetic Use (Vietnam)
Federal · FDA Import Refusal · 2026-09-14FDA import refusal: Implant, Dermal, Collagen for Aesthetic Use (Sweden)
Federal · FDA Import Refusal · 2026-09-10FDA import refusal: Lidocaine (India)
Federal · FDA Import Refusal · 2026-09-10FDA import refusal: Tirzepatide (Anti-diabetic) (Japan)

MedSpaRadar

MedSpaRadar is regulatory monitoring and reference: it summarizes public laws, regulations and agency actions and links each to its source. It is not legal, medical, or compliance advice, and using it creates no attorney-client relationship. A summary can lag its source or leave out detail, and monitoring itself can be interrupted — so an absence of alerts means nothing reached you, not that nothing happened. Read the cited source, check its effective date, and confirm any change to your operations or clinical practice with qualified health-law counsel and your medical director.

Legislative data via LegiScan (CC BY 4.0). Federal data published by the U.S. FDA and the Office of the Federal Register.

Sample snapshot as of 2026-09-26.

1 · Regulatory changes affecting your practice

Action required (31)

TX HB3749: Relating to the regulation of the provision of elective intravenous therapy.

TX SB2696: Relating to the regulation of the performance of cosmetic injections; requiring an occupational certificate; authorizing fees.

TX SB1117: Relating to the administration of botulinum toxin by dentists.

Primary Source Monitoring: Former Connecticut Resident Guilty of Operating Websites to Illegally Sell Misbranded and Unapproved Drugs

Primary Source Monitoring: Korea Filler Experts - 718706 - 11/03/2025

Primary Source Monitoring: FDA clarifies policies for compounders as national GLP-1 supply begins to stabilize

Primary Source Monitoring: Eli Lilly v. Instant Rx (E.D.N.Y.) — Consent Judgment and Permanent Injunction as to defendants Dispensing Physician Consultants, Inc. d/b/a Ira's Di…

Primary Source Monitoring: Med Spa Owner Sentenced to 46 Months in Prison for Performing Thousands of Counterfeit Botox and Filler Injections

Primary Source Monitoring: Peak Performance Peptides - 735127 - 08/24/2026

FDA recall (Class II): Semaglutide 6.75mg (4.5 mg/mL), 1.5 mL Sterile Multi-Dose Vial, Rx Only, For Subcutaneous Injection Only, Apollo care, …

Primary Source Monitoring: Eli Lilly and Company v. Lone Star Peptide Co. LLC (4:26-cv-06562) — District Court, S.D. Texas

FDA recall (Class II): Liraglutide Injection, 18 mg/3 mL (6 mg/mL), Rx only, Manufactured for: Lupin Pharmaceuticals, Inc., Naples, Fl 34108, …

FDA / Federal Register Notice: List of Bulk Drug Substances for Which There Is a Clinical Need Under Section 503B of the Federal Food, Drug, and Cosmetic Act

FDA recall (Class II): Semaglutide-Glycine-Cyanocobalamin Injectable, 2.5 mg, 5 mg, 1 MG/ML, 0.5 mL vials, Rx only, Northwest Compounders, Bea…

Primary Source Monitoring: Utah Licensed Osteopathic Physician Indicted for Allegedly Receiving Misbranded Drugs from China and Selling them to Patients

FDA recall (Class II): Tirzepatide Inj, 15mg x 4, Sterile Multi-Dose Vial, Rx only, Nomida, 25055 W Valley Pkwy, Suite 106, Olathe, Ks 66061, …

FDA recall (Class II): Semaglutide Inj., 2 mg x 5, Sterile Multi-Dose Vial, Rx only, Nomida, 25055 W Valley Pkwy, Suite 106, Olathe, Ks 66061,…

FDA recall (Class II): Semaglutide, For Rx compounding use only, packaged in a) 1g, NDC 84385-106-01; b) 5g, NDC 84385-106-02; c) 10g, NDC 843…

FDA recall (Class II): Wegovy (Semaglutide) Injection, 0.5 mg/0.5 mL, 4 Single-Dose Prefilled Pens, Manufactured by: Novo Nordisk A/S, DK-2880…

FDA recall (Class II): Semaglutide Injection, 2.5mg/1mL (2.5 mg/mL), 1mL Multidose Vial, For Subcutaneous Use, Rx Only, Mfd by: ProRx, 619 Jef…

FDA recall (Class II): Tirzepatide Injection, 27 mg/3 mL (9 mg/mL), 3mL Multidose Vial, For Subcutaneous Use, Rx Only, Mfd by: ProRx, 619 Jeff…

FDA recall (Class II): Tirzepatide, 60mg/10 mL for Injection, 10mL vial lyophilized, all presentations, GenoGenix, LLC, 2840 Nw 2nd Ave Ste 20…

FDA recall (Class II): Semaglutide with B12 for Injection, all strengths and presentations, GenoGenix, LLC, 2840 Nw 2nd Ave Ste 204 Boca Raton…

FDA recall (Class II): Semaglutide, 2.5 mg/mL injection, 2 mL., Boothwyn Pharmacy

FDA recall (Class II): Tirzepatide + Niacinamide 16.6 mg + 1.0mg/0.5 mL Inj Sol, Inject 0.5 mL (50 units on syringe) subcutaneously, Sterile, …

FDA recall (Class II): Semaglutide + Cyanocobalamin 2.67 mg + 0.25mg/0.5 mL Inj Sol, Inject 0.5 mL (50 units on syringe) subcutaneously, Steri…

FDA recall (Class II): Tirzepatide Injections, 30mg/mL, pre-filled syringe, Thrive Health Solutions, 88 Inverness, Cir E, Suite A-204, Englewo…

FDA recall (Class II): Semaglutide, 2.5 mg/mL, pre-filled syringe, Thrive Health Solutions, 88 Inverness, Cir E, Suite A-204, Englewood, Co 80…

FDA recall (Class II): Wegovy (Semaglutide) injection, 2.4 mg/0.75 mL, 4 Single-Dose Prefilled Pens per Carton, For Subcutaneous Use Only, Rx …

FDA / Federal Register Notice: Interim Policy on Compounding Using Bulk Drug Substances Under Section 503B of the Federal Food, Drug, and Cosmetic Act; Guidance for Industry; Availability

FDA / Federal Register Notice: Interim Policy on Compounding Using Bulk Drug Substances Under Section 503A of the Federal Food, Drug, and Cosmetic Act; Guidance for Industry; Availability

Watch — moving in other states (3)

TN HB2044: an Act to amend Tennessee Code Annotated, Title 63; Title 68, Chapter 11, Part 2 and Chapter 1042 of the Public Acts of 2024, relative to certified medical assistants.

IN SB0282: Compounding drugs; registration of medical spas.

RI H5351: Mandates cosmetic medical procedures be performed by a physician, PA, APRN, or delegated to a qualified non-physician, non-PA or non-APRN under the supervision of a physician, physician assistant, or advanced practice registered nurse.

Devices & facility (4)

FDA device recall (Class II): Product Name: DermaV Laser System Model/Catalog Number: DermaV Medical laser device that delivers pulsed laser energy a…

FDA Warning Letter: Advance-Esthetic LLC (Devices)

FDA device recall (Class II): Clarity II Laser System; Model No. 1110200210.

FDA device recall (Class II): Brand Name: Leaseir Product Name: Leaseir Mhr Xcell Model/Catalog Number: Mhr 110-b Software Version: 1.5.0.0 Product D…

Medications, injectables & compounding (22)

Primary Source Monitoring: Hefner v. Rock Valley Compounding Pharmacy, LLC (3:26-cv-01298) — District Court, S.D. Illinois

Primary Source Monitoring: Human Drug Compounding Policies and Rules

Primary Source Monitoring: Agency Information Collection Activities; Proposals, Submissions, and Approvals: Registration of Human Drug Compounding Outsourcing Facilities Under …

FDA Warning Letter: Peptide Partners, LLC (Drugs)

FDA Warning Letter: Royal Peptides LLC (Drugs)

FDA Warning Letter: Peak Performance Peptides (Drugs)

Primary Source Monitoring: Illinois Man Charged With Scheme To Impersonate Doctors And Make False Statements To Obtain GLP-1 Medications

FDA / Federal Register Notice: Outsourcing Facility Fee Rates for Fiscal Year 2027

FDA / Federal Register Notice: List of Bulk Drug Substances for Which There Is a Clinical Need Under Section 503B of the Federal Food, Drug, and Cosmetic Act; Extension of Comment Period

FDA Warning Letter: Herbal Dermals Ltd (Drugs)

FDA Warning Letter: Herbal Dermals Ltd (Drugs)

FDA Warning Letter: Wholesale Peptide (Drugs)

FDA Warning Letter: Herbal Dermals Ltd (Drugs)

FDA shortage: Liraglutide Injection (Injection) — Currently in Shortage

Primary Source Monitoring: Agency Information Collection Activities; Proposed Collection; Comment Request; Human Drug Compounding Under Sections 503A and 503B of the Federal Fo…

Primary Source Monitoring: California Doctor Convicted of $45M Botox Fraud Scheme Targeting Medicare

FDA Warning Letter: Fresenius Kabi Compounding, LLC (Drugs)

Primary Source Monitoring: Pharmacy Compounding Advisory Committee; Notice of Meeting; Establishment of a Public Docket; Request for Comments-Bulk Drug Substances Nominated for…

FDA Warning Letter: Mile High Compounds (Drugs)

FDA Warning Letter: Gram Peptides (Drugs)

Primary Source Monitoring: Agency Information Collection Activities; Submission for Office of Management and Budget Review; Comment Request; Human Drug Compounding Under Sectio…

FDA / Federal Register Notice: Outsourcing Facility Fee Rates for Fiscal Year 2026

Cross-cutting (18)

Primary Source Monitoring: Drug Shortages | Additional News and Information

Primary Source Monitoring: Compounding and the FDA: Questions and Answers

Primary Source Monitoring: Compounding Information for States

Primary Source Monitoring: Illinois Man and Indiana Woman Sentenced Respectively to 70 Months and 16 Months in Prison For Selling Unapproved Drugs in Interstate Commerce

Primary Source Monitoring: Wilson v. Lexington Compounding Pharmacy, Inc. (5:26-cv-00273) — District Court, E.D. Kentucky

FDA Warning Letter: Spa De Soleil, Inc. (Drugs)

Primary Source Monitoring: Massachusetts Couple Sentenced to Prison for Importing Misbranded Drugs From China and Selling Them to Customers in U.S. for Performance Enhancing Pu…

Primary Source Monitoring: Pagan v. Glow Med Spa (1:26-cv-24474) — District Court, S.D. Florida

FDA Warning Letter: ketaminelab.org (Drugs)

FDA Warning Letter: Herbal Dermals LLC Fz (Drugs)

Primary Source Monitoring: Med Spa Owner Pleads Guilty to Performing Illegal Injections Using Unapproved Prescription Drugs

Primary Source Monitoring: Advisory Committee; Pharmacy Compounding Advisory Committee; Renewal

FDA Warning Letter: Active Cosmetics Manufacturing Inc (Drugs)

FDA Warning Letter: Foshan Miwei Cosmetics Co., Ltd. (Drugs)